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Inversions Under Siege: New Treasury Regulations Issued

Volume 3 No 4   /   Read Article

By Philip R. Hirschfeld

On April 4, 2016, the Treasury Department issued a third round of new rules under Code §7874 aimed at halting the wave of inversions. Already, at least one inversion transaction, involving pharmaceutical giants Pfizer and Allergan, has been scuttled. Beyond that, the new rules resuscitate regulations issued under Code §385. Philip R. Hirschfeld explains.  See more →